Skylands Capital, LLC
Privacy Policy Notice

When you choose to invest your money with Skylands Capital, LLC (“Skylands”), you not only entrust us with your investments, but also with your personal information and financial data. Just as we are dedicated to managing your money well, we are also committed to respecting your privacy and protecting the personal information that you share with us. Federal law requires us to tell you how we collect, share and protect your personal information. Please read this Privacy Notice carefully.

In order to provide investment products and services that best suit your needs, we collect certain personal information about you from subscription agreements, account applications, investment advisory agreements and other documents. Such personal information may include your name, address, social security number or taxpayer identification number, birth date, driver’s license data, telephone number, fax number, e-mail address, business affiliations, bank information, assets, income, beneficiaries, and custodial accounts.

We do not disclose personal information to third party non-affiliates except as necessary to service your account or as permitted or required by law. In order to manage and service your account, we may provide certain personal information to various firms that provide trading and execution, settlement and custodial functions, administration, audit, tax and legal work. We may be required to disclose personal information to a government or regulatory body in connection with an examination or investigation. We may share certain account and tax information with your personal accountant, attorney and/or financial consultant per your written or verbal instructions. These non-affiliated third parties have an obligation, contractual or otherwise, to protect the confidentiality of your information and to use it strictly for the purpose for which the disclosure is needed.

We do not share your personal information with third party non-affiliates for marketing or joint marketing purposes, nor do we disclose your creditworthiness to third party non-affiliates unless specifically instructed by you. Note that Skylands does not have any affiliates (i.e., companies related by common ownership or control).

To protect your personal information, we have established security measures which include computer safeguards and secured files and buildings.

We will continue to adhere to the privacy policy described in this notice even after your account is closed or becomes inactive. This notice complies with the requirements of Regulation S-P under the Gramm-Leach-Bliley Act.

For questions about Skylands’ Privacy Notice, please contact Virginia Riesing, Chief Compliance Officer at (414) 256-3380.

Privacy Policy Supplement for California Residents

This notice supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended (the “CCPA”), to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in this Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

Categories of Personal Information We Collect: We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months:

• Identifiers, such as name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and drivers’ license or state identification card number);
• Other customer records, such as telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets);
• Protected classification characteristics under California or federal law, such as date of birth, citizenship and birthplace;
• Commercial information, such as account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s) and/or any separately managed account(s) receiving this notice (collectively, “Clients”), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable Client(s); and
• Internet or other electronic network activity information, such as information regarding your use of our website and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.

Within the last twelve (12) months, we have shared each of the categories of personal information collected with non-affiliated third-party service providers as set forth above, and we collect personal information from the sources set forth above.

Purposes for Collecting Personal Information: We may collect or share the personal information we collect about you for one or more of the following business or commercial purposes:

• performing services to you, including:
  • the administrative processes (and related communication) in preparing for the admission of investors to the fund(s) and/or onboarding separately managed account client(s);
  • ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund(s) and/or onboarding separately managed account client(s);
  • the performance of obligations under the governing documents of the Clients (and all applicable anti-money laundering, Know Your Customer and other related laws and regulations) in assessing suitability of potential investors in the applicable Client(s);
  • ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the Clients in accordance with their governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, preparing tax information, processing contributions and distributions and financing;
  • keeping investors informed about the business of Skylands or the general partner of the applicable fund, including offering opportunities to make investments to other Skylands funds and related advertising;
  • auditing and verifications related to investor interactions, including verifying the quality and effectiveness of services and compliance;
  • detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and
  • complying with U.S., state, local and non-U.S. laws, rules and regulations.

We do not sell any of the personal information we collect about you to third parties.

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including our compliance with U.S., state, local and non-U.S. laws, rules and regulations.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, and disclosure of personal information specific to you over the last twelve (12) months. Such information includes:

• The categories of personal information we collected about you;
• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting such personal information;
• Categories of third parties with whom we share the personal information;
• The specific pieces of personal information we have collected about you; and
• Whether we disclosed your personal information to a non-affiliated third-party, and if so, the categories of personal information that each recipient obtained.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please e-mail us at the following e-mail address: vr@skylandscapital.com

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may use existing investor contact information that we have on file in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline. For questions about this supplement, please contact Virginia Riesing, Chief Compliance Officer at (414) 256-3380.